As an ISB more will be expected of you in several ways.
First, the bank's community development activities will go from no responsibility to a critical responsibility, absolutely essential to passing your next CRA exam, even if it's tomorrow. So you have no time to waste. It's important to collect any CD activities (lending, services, or investments) retroactive to your last CRA exam. Yes, you heard that correctly - retroactive to your last CRA exam - or at least one year. Why, because once you become an ISB you are immediately subject to ISB CRA exam standards. In other words, your CD responsibilities began as you were approaching ISB status. I remember asking a Field Review Supervisor about this and she told me in no uncertain terms that as a bank approaches ISB status it is incumbent to engage in CD activities because the CD test will be administered for the bank's very next CRA exam and there is no leeway for not engagin in sufficient CD activity.
Second, although you are not required to report your CRA activity there will be a higher expectation that you are collecting and monitoring your CRA performance. Heck, if I were a CRA officer at an ISB I would be collecting and monitoring the data whether I was reporting or not because my bank (and I) would be held responsible to perform under CRA. What sane person would subject themselves to that kind of responsibility without collecting and monitoring the data? Of course, if you are a masochist maybe you would enjoy the anxiety of going into a CRA exam blind.
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